I’m not sure you should get too excited about those warning letters. The one to Honest Globe seems to be more of a reprimand of the company for suggesting that they are selling an approved OTC product. I don’t see the FDA using “OTC” in reference to their product, but rather in several explanations of why it doesn’t qualify as the OTC they are advertising it as. As for the letter to BioLyte, this one addresses several products, one of which is a colloidal silver preparation that is marketed as OTC. As far as I can see, the FDA never uses the term “OTC” in reference to their CBD product and actually states that it does not qualify [as OTC] under section 505G(a)(1) or (2). The problem seems to be that, because of the claims being made by the respective manufacturers, the CBD products in question are being sold as non-prescription drugs, implying that they are therefore being sold as OTC. The FDA simply appears to be telling these companies that their products can not be sold as OTC medications because they have not been approved as such and do not qualify for exemptions. The non-OTC clarifications are being offered in response to the language used by the manufacturers, not as any novel classification by the FDA. Seems to me the FDA is maintaining the status quo. Reply